Yana Trubitsyna of Regartis looks at the advantages of collecting and storing the data on SVHC substances , and shares some tips and tricks on how to achieve SCIP compliance
SVHCs & SCIP : Overcoming obstacles on your way to compliance
Yana Trubitsyna of Regartis looks at the advantages of collecting and storing the data on SVHC substances , and shares some tips and tricks on how to achieve SCIP compliance
A product in this context can be anything from the simplest to the most complex
Since 5 January 2021 , companies based in the EU have had an obligation to notify articles containing substances of very high concern ( SVHCs ) included in the REACH Candidate List for Authorisation to the SCIP database . SCIP stands for Substances of Concern In articles as such or in complex objects ( Products ).
Some background
The SCIP database was established under the Waste Framework Directive ( WFD ). This effectively extends the REACH Article 33 duties of suppliers of articles to communicate information on SVHC substances in their articles down the supply chain by requiring them to submit this information also to ECHA .
The obligation to notify SVHCs in articles concerns all articles containing Candidate List substances in concentrations of above 0.1 % w / w that are placed on the EU market . This applies to producers , assemblers , importers and distributor of articles based in the EU , but not to other supply chain actor supplying articles directly and exclusively to consumers .
It is worth mentioning that any consumer has a right to enquire about the presence and content of SVHCs in a purchased product . It can be anything : a bicycle ( our favourite example from ECHA ’ s guidance ), a computer mouse , track shoes or a bed . Companies must provide the information to the consumer within 45 days upon request , meaning that you need to go up the supply chain until you receive the information and are able to share it with the consumer .
An important note : companies within the same corporate group placing articles containing SVHC substances on the market should submit their own SCIP notification . It is possible to use reference tools developed by ECHA for users ’ convenience and to prevent reporting and accumulation of redundant data in the system .
There are two tools : Simplified SCIP Notification ( SSN ) and ‘ referencing ’ in a SCIP notification dossier . Both use the SCIP notification number , the unique alphanumeric code generated as an outcome of successful SCIP notification , as a reference to data already submitted to ECHA by a company or other duty holder .
The process of reporting itself is fairly straightforward once all the required data is available . The data collection , however , may be quite a challenge , especially when articles are imported from outside the EU , because companies from most
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